Public Comments 2019 (191-

The New Progressive Alliance periodically makes Public Comments by itself or with other organizations to federal agencies and legislative bodies in the United States and Canada in support of the Unified Platform. They are reproduced here in full and also briefly mentioned with our other activities in the Annual Reports and on our website under "News."

The New Progressive Alliance at http://newprogs.org/ urges you to oppose the Pacific Connector fracked gas pipeline and the Jordan Cove LNG export terminal. Not only will this be the largest source of climate pollution in Oregon, the bad effects extend far beyond the borders of Oregon.

The Jordan Cove LNG would transport fracked gas from the Canadian and US Rockies to the southern Oregon Coast, requiring the 229-mile Pacific Connector fracked gas pipeline across private and public land. This would require taking private land through eminent domain. It would also necessitate a 95-foot wide clear-cut through southwest Oregon’s forests and farms.

The highly explosive export facility at the Port of Coos Bay would be located in a tsunami hazard zone, subjecting thousands of people to hazardous burns in the case of an accident. This project would pollute nearly 500 waterways, harm salmon habitat, impact hundreds of landowners, threaten tribal territories and burial grounds, raise energy prices, and become the largest source of climate pollution in Oregon. This would impact more than 485 rivers and streams, including the Klamath, Rogue, Umpqua, Coos, and Coquille Rivers. At each place where the 36-inch pipeline crosses waterways, the construction will harm habitat for fish and pollute clean water. The project would also require dredging out and fundamentally re-shaping the Coos Bay estuary.

-Disturbing and re-suspending toxic materials in and around waterways;

-Permanently destroying wetlands;

-Potentially releasing drilling chemicals and other contaminants into rivers and streams;

-Crossing the rivers and streams that are the drinking water source for 12 public drinking water systems and more than 116,000 Oregonians;

-Fundamentally altering the Coos Bay estuary, increasing murkiness and degrading habitat for salmon and shellfish, like oysters and clams;

-Modifying the navigation channel at Coos Bay that would interfere with the ability of the public to access these areas for fishing and recreation; and

-Increasing ship traffic in the navigation channel that could increase invasive species released through ballast or engine cooling water.

The answer is not natural gas obtained by fracking - "in essence, explode a pipe bomb a few thousand feet beneath the surface, fracturing the surrounding rock." Unregulated by the EPA because of congressional action combined with the support of Presidents Obama and Trump, companies refuse to even reveal the chemicals they are "fracking" with, nobody is monitoring the pollution to water and our aquifiers, and nobody is factoring the release of methane as a GHG. Of the 750 chemicals that can be used in the fracking process, more than 650 of them are toxic or carcinogens, according to a report filed with the U.S. House of Representatives in April 2011.

For the reasons stated in this letter the New Progressive Alliance respectfully requests the Oregon Department of State Lands deny the removal-fill permit and to oppose the Pacific Connector fracked gas pipeline and the Jordan Cove LNG export terminal.

Public Comment 192: January 2019 – NY Governor – Election Reform

January 4, 2019

Dear Governor Cuomo:

New York has an unprecedented opportunity to lead the nation -- quite literally -- on campaign finance reform, with a small donor matching system. We write to request your help.

As you know, Speaker Pelosi and key leaders in Congress are spearheading an effort to make democracy reforms the first bill in the 116th Congress. In a November 25 oped in the Washington Post, entitled, “The Democratic Majority Will Restore Democracy,” Pelosi and Representative Sarbanes wrote: “Americans went to the polls and sent a powerful message: The election not only was a resounding verdict against Republicans' assault on Americans' health care and wages, but also it was a vote to rescue our broken democracy.

First among the democracy-rescuing reforms they described was campaign finance reform:

We must also empower hard-working Americans in our democracy by building a 21st-century campaign-finance system - combining small-donor incentives and matching support to increase and multiply the power of small donors. Wealthy special interests shouldn't be able to buy more influence than the workers, consumers, and families who should be our priority in Washington.

We know you are aware of voter hunger for reform, and we know you believe in amplifying the power of small donors to limit the power of big money in our politics. You've called for it every year you've been in office.

With Democrats taking over the U.S. House of Representatives, the nation is heading down the track that New York is already on. The destination is a new era of democracy reforms such as small donor public financing, automatic voter registration, and early voting. New York, under your leadership, can get there first, and in so doing provide a boost to the broader national effort.

That is precisely why we write. Show the nation how it can be done. Inspire Congress and give something to candidates to point to in 2020. We'll work hard to pass a federal bill in the U.S. House this month. We then hope to look to New York as a model for the nation.

Luckily, you are not alone. You have two legislative leaders who have sponsored small donor matching system bills. You also have us, and many others hoping to see this happen.

The New Progressive Alliance at http://newprogs.org/ joins Washington Governor Jay Inslee and Washington state Attorney General Bob Ferguson in urging you to reject a new plan to reclassify nuclear waste. It would allow the federal government to walk away from its obligation to clean up millions of gallons of toxic, radioactive waste at the Hanford, Washington Nuclear Facility.

We in Washington state did not shrink from our patriotic duty and supported the making of our country’s nuclear arsenal. Hanford’s underground tank waste is the deadly legacy of a half-century of plutonium production for the nation’s nuclear arsenal. Hanford tanks hold 60 percent of the nation’s most dangerous nuclear waste.

The half-life of the main fuel, U-235, is 703.8 million years. Plutonium is also routinely created in the process of running a nuclear plant. It is highly toxic and its various isotopes have half-lives ranging from about 25,000 to 80 million years. These extremely dangerous substances will require secure storage and protection for a very long period of time and we do not have an agreed upon place to store or agreed way to transport nuclear waste. Changing it from high level to low level waste is unfair to tribal leaders, Hanford workers, public safety officials, and surrounding communities.

Please do the right thing and keep the government promise that has been made for decades to clean up Hanford.

Public Comment 194: January 2019 – Reopen Government

The New Progressive Alliance with over 280 other organizations wrote the President and Congress about the adverse health impacts of the government shutdown.

January 17, 2019

The President

The White House

1600 Pennsylvania Avenue, NW

Washington, DC 20500

United States Senate

Washington, DC 20510

United States House of Representatives

Washington, DC 20515

With the partial government shutdown nearing the four-week point, the undersigned organizations call on Congress and the President to immediately reopen the government to minimize any further impact on the public’s health and wellbeing. Several agencies’ ability to provide critical services, ranging from food and environmental risk inspections to health services, have already been drastically reduced or are threatened if the shutdown continues.

We fear a prolonged shutdown will cause needless suffering and have long-lasting health consequences. Basic health protections could be endangered by an ongoing shutdown. The Food and Drug Administration (FDA) is suspending its routine food inspections except at “high-risk facilities,” and its ability to enforce food safety rules may be sharply impaired as 40 percent of its workforce is furloughed. The FDA oversees 80 percent of the food supply, and regular inspections and enforcement help stop foodborne illness before people get sick. The FDA also will not be able to assess new drug and device applications if the shutdown continues, meaning life-saving innovations will take longer to come to market.

There are also increased environmental risks to the health of the public. The Environmental Protection Agency has suspended its inspections of chemical factories, power plants and water treatment operations while the Agency for Toxic Substances and Disease Registry (ATSDR) is no longer investigating and assessing environmental health threats.

The shutdown is having cascading impacts on the public’s health through loss of income and potential cuts to programs that families rely on for health and economic stability. Access to nutrition and food assistance, breastfeeding support and infant nutrition through U.S. Department of Agriculture programs is critical to maintaining health and performance in school and work. Programs such as Supplemental Nutrition Assistance Program (SNAP) and the Special Supplemental Nutrition Program for Women, Infants and Children (WIC) are at serious risk of benefit cuts if the shutdown continues. And 800,000 Americans are furloughed or working without paychecks, which puts their ability to pay rent and utilities, access medicines, and put food on the table in jeopardy. Residents simply cannot maintain their health without stable housing, food and medical care. Indian Country has been disproportionately impacted by the shutdown, which is curtailing health care and programs for American Indian communities. The Indian Health Service (IHS) receives its funding through the Department of the Interior, Environment and Related Agencies Appropriations bill, so tribal governments are cutting other services and scraping together scarce dollars to keep health clinics operational in the short term. Many HIS employees working without pay are already reportedly looking for other jobs, which would be a huge blow to an agency that has great difficulty recruiting and retaining medical professionals in rural and remote 2 areas. The shutdown is destabilizing Native health delivery and health care provider access, as well as destabilizing tribal governments, families, children and individuals. Services will be cut and serious consequences to health and safety will be the result if the shut down is not ended soon.

A prolonged shutdown will continue to put the health and safety of the nation’s residents at risk. It is vital that Congress and the President work to reopen the government as soon as possible to minimize the effects of the impasse.

We, the undersigned organizations, ask that you bring to the U.S. Senate floor legislation that immediately reopens the federal government, extends funding for all agencies closed or partially closed during the government shutdown and excludes any of the extraneous requests demanded by President Donald Trump on immigration or funding for his proposed southern border wall.

We also urge you and members of your caucus to vote in favor of such legislation to end the partial shutdown that has disrupted the lives and livelihoods of 800,000 federal workers and contract workers around the country, their families and their communities – and inflicted tens of billions of dollars of damage on our environment and economy.

Furthermore, we urge you, your Republican colleagues and President Trump to abandon the strategy of taking legislative hostages that harm ordinary people in our country to achieve policy goals opposed by a large majority of voters. This is extortion, plain and simple. It is outrageously undemocratic and a betrayal of the American people.

Sincerely,

Adirondack Wildlife Refuge and RehabilitationAlaska Wilderness LeagueAllied ProgressAmerican Federation of State, County and Municipal Employees (AFSCME)American Federation of TeachersCenter for American ProgressCenter for Popular DemocracyCenter for Progressive ReformCenter for Science in the Public InterestClean Water ActionCoalition of Labor Union WomenCommunications Workers of AmericaConsumer Federation of AmericaDefenders of WildlifeDemosEarthjusticeEarthworksEconomic Policy InstituteEndangered Species CoalitionEnvironmental Working GroupFirst Person PoliticsFood & Water WatchFriends of the EarthGreenpeaceHealth Justice InnovationsHealthy Babies Healthy FamiliesHerd on the HillHispanic FederationInterfaith Worker JusticeLabor of Love Safety Training and ConsultingLeadership Conference on Civil and Human RightsLeague of Conservation VotersLos Padres ForestWatchMain Street AllianceMaine AFL-CIONAACP Legal Defense and Educational Fund, Inc.NARAL Pro-Choice AmericaNational Advocacy Center of the Sisters of the Good ShepherdNational Association of Consumer AdvocatesNational Consumer Law Center (on behalf of its low income clients)National Consumers LeagueNational Council of Jewish WomenNational Employment Law ProjectNational Fair Housing AllianceNational Immigration Law CenterNational Latina Institute for Reproductive HealthNational Partnership for Women & FamiliesNational Women's Law CenterNETWORK Lobby for Catholic Social JusticeNew Jersey Association on CorrectionNew Progressive AllianceOxfam AmericaPAIPartnership for Policy IntegrityPartnership for the Public GoodPeople For the American WayPlanned Parenthood Federation of AmericaPride Center of Staten Island, Inc.Public CitizenPublic Justice CenterRachel Carson CouncilRestaurant Opportunities Centers UnitedRhode Island Committee on Occupational Safety and HealthSafeWork WashingtonSciencecorpsService Employees International UnionService Employees International Union, Local 32BJSexuality Information and Education Council of the United States (SIECUS)Sierra ClubSouthern Border Communities CoalitionTruman National Security ProjectUndocuBlack NetworkUnited SteelworkersUnited We DreamVoices for ProgressThe Wilderness SocietyThe Worker Institute at Cornell University’s ILR SchoolWorkplace Fairness

Public Comment 196: February 2019 - Washington state Environmental Laws

February 1, 2019

The state of Washington is moving ahead in many environmental legislative actions. Carbon Washington is a longtime ally of the New Progressive Alliance (see Allies http://www.newprogs.org/allies) and is pushing these laws.

Today, our democracy is out of balance, and that makes it harder to solve the big problems facing our country and our communities. Our current system allows powerful corporate and wealthy interests to regularly defy the foundational principles of fairness, equity, ethics, accountability, and respect for the rule of law, with the unfortunate result being a government that is more responsive and accountable to wealthy political donors than to the public. The great news is that right now we have a real opportunity to move solutions that work.

We, the undersigned organizations, support the efforts by Members of Congress to restore balance to our democracy through the sweeping new reform package, the For the People Act, or H.R. 1.

We are writing now to call your attention to the provisions in the For the People Act that would shine light on the out-of-control secret corporate influence in our democracy, which has become so pervasive since the U.S. Supreme Court’s decision in Citizens United v. FEC. When this detrimental decision came down in 2010, it opened up the floodgates for corporations to spend unlimited undisclosed amounts of money to influence American elections and in turn affect policy outcomes. Noting the danger of “dark money” for both American democracy and the shareholders of the companies that are spending in secret, a strong coalition of diverse allies has been working together since the decision to bring corporate spending in politics into the light.

The Supreme Court’s decision to give corporations the right under the First Amendment to spend unlimited funds from their corporate treasuries to support or attack candidates is troubling and investors concerned about the value of their investments and citizens concerned about the future of American democracy have looked to the Securities and Exchange Commission (SEC) to take action and require disclosure of public companies’ political spending.

Without direction from the SEC, there are no rules or procedures established in the United States to ensure that shareholders – those who actually own the wealth of corporations – are informed of, or have the right to approve, decisions on spending their money on politics. Investors want more disclosure in order to make sound investment decisions. That is why 1.2 million comments- the most in the agency’s history- have come into the SEC on the corporate political spending disclosure rulemaking petition from diverse stakeholders including the late founder of Vanguard, John Bogle, five state treasurers, a bipartisan group of former SEC chairs and commissioners, and investment professionals representing $690 billion in assets.

Currently, the SEC is barred from finalizing the corporate political spending disclosure rulemaking due to a poison pill policy rider inappropriately included in the Financial Services and General Government Appropriations bill. We, the undersigned organizations, believe the SEC should be allowed to and encouraged to move forward with the rulemaking that would require public companies to disclose to their shareholders and the public how they spend money in politics. This information is material to investors- the constituency the SEC is responsible for protecting. Among its many critical reforms, the For the People Act strikes this harmful policy rider from the Appropriations bill. It also includes other important disclosure provisions such as closing loopholes that allow foreign money to disrupt our elections and shining a light on who is funding digital political ads.

Our organizations support this sweeping reform package, as it works to make it easier, not harder to vote, end the dominance of big money in our politics, and ensure that public officials truly work for the public. We encourage Members of Congress to support this legislation. Our democracy cannot wait any longer.

Sincerely,

Boston Common Asset Management

Campaign for Accountability

Common Cause

Democracy 21

Domini Impact Investments LLC

End Citizens United Action Fund

Franciscan Action Network

Greenpeace

Harrington Investments, Inc.

Interfaith Center on Corporate Responsibility

International Corporate Accountability Roundtable

League of Women Voters of the United States

Missionary Oblates of Mary Immaculate JPIC Office

MomsRising

National Association of Social Workers

NETWORK Lobby for Catholic Social Justice

New Progressive Alliance

NorthStar Asset Management, Inc.

Patriotic Millionaires People Demanding Action

People for the American Way

Poligon Education Fund

Pride at Work

Progressive Turnout

Project Public Citizen

Union of Concerned Scientists

Unitarian Universalist Association

Voices for Progress

Women's Institute for Freedom of the Press

Public Comment 198: February 2019 - Congress fund CDC

Despite increasing health problems such as the Flint water crisis and an outbreak of measles in Washington state, the Center for Disease Control (CDC) is being steadily decreased. The New Progressive Alliance with the below organizations asks that CDC be adequately funded.

February 12, 2019

American life expectancy has declined, largely due to heart disease, stroke, diabetes, suicides, and drug overdoses. CDC funds state and local public health efforts to prevent these diseases—and more, not less, is needed. Federal investment in public health has not kept pace with inflation nor the considerable challenges posed by infectious disease outbreaks, extreme weather events, and other emergencies, such as the Flint water crisis.

According to a 2017 report by the Trust for America’s Health, of the $3.5trillion spent annually on healthcare, only three percent of all health spending is directed to public health, which includes federal, state, and local resources. That equates to an average of $280 per person. By contrast, total healthcare spending is $10,739 per person.

Reductions in the public health workforce strain the ability of state and local public health departments to protect and promote population health. From 2012-2016, the estimated number of full-time health agency employees decreased by three percent. By 2020, the percentage of health agency employees who are eligible for retirement will reach 25 percent.

Academy of Nutrition and Dietetics

Academy Health

Adult Congenital Heart Association

Advocates for Better Children's Diets

American Academy of Family Physicians

American Association for Dental Research

American Association for the Study of Liver Diseases

American Association of Colleges of Pharmacy

American Association of Poison Control Centers

American College of Preventive Medicine

American Diabetes Association

American Heart Association

American Lung Association

American Public Health Association

American School Health Association

American Sexual Health Association

American Society for Microbiology

American Society of Hematology

Asian and Pacific Islander American Health Forum

Association of Women's Health, Obstetric and Neonatal Nurses

Association for Professionals in Infection Control and Epidemiology

Association of Maternal & Child Health Programs

Association of Public Health Laboratories

Association of State and Territorial Dental Directors

Association of State and Territorial Health Officials

Association of University Centers on Disabilities (AUCD)

Big Cities Health Coalition

Campaign for Tobacco-Free Kids

Children's Hospital Colorado

Clear Way Minnesota

Colorado Association of Local Public Health Officials

Cooley's Anemia Foundation

Council of State and Territorial Epidemiologists

Counter Tools

Epilepsy Foundation

GlaxoSmithKline Consumer Healthcare

Health Resources in Action

Healthy Schools Network

Hogg Foundation for Mental Health

Immunize Nevada

Impetus -Let's Get Started LLC

Intermountain Public Health Consulting, LLC

Infectious Diseases Society of America

Jeffrey Modell Foundation

Kymm Ballard Consulting & Asst. Professor at Campbell University

LIVESTRONG

March of Dimes

Maryland Public Health Association

NACDD

NAPHSIS

NASTAD

National Association of County and City Health Officials

National Association of Epilepsy Centers

National Association of School Nurses

National Coalition of STD Directors

National Hemophilia Foundation

New Progressive Alliance

North American Association of Central Cancer Registries (NAACCR)

Pitkin County Public Health

Prevent Blindness

Prevention Institute

Public Health Institute

Redstone Global Center for Prevention and Wellness

Sage Transformations

SAS

Society for Public Health Education

Society of State Leaders of Health and Physical Education

Stewards of Change

The AIDS Institute

The Ayuda Foundation/Island Girl Power GUAM

The Institute for Family Health/Bronx Health REACH

The National REACH Coalition

Tobacco Control Network

Triage Cancer

Trust for America's Health

Women Heart

YMCA of the US

Public Comment 199: March 2019 - Needed Changes for HR1

Green Party Presidential Candidate Sedinam Curry today called on Congress to make significant changes in House Democrats' legislative centerpiece HR1, the "For The People 2019 Act", particularly in the portions of the Act having to do with campaign matching funds.

"While there is a great deal of good in this legislation, making voting more accessible and more secure; laying the groundwork to overturn the horrible Citizens United v. FEC decision; strengthening our system of public financing of elections; and more, there are a couple of very serious problems with the bill," Moyowasiza-Curry explained, "and I urge members of the House of Representatives who really do care about making our political system more democratic to fix those flaws before voting on this legislation."

Foremost among the problems are significant increases to the fundraising thresholds for candidates to qualify for Federal matching funds. "Increasing the threshold for qualifying for Federal matching funds for Presidential candidates from $5000 per state to $25,000 per state in a minimum of 20 states will throw a huge barrier in the way of political parties other than the 'major' parties, who don't even participate in the funding system anymore. The public has shown so many times that they want more options, and legislation to make our system more democratic should not at the same time make us less democratic," Moyowasiza-Curry noted.

Moyowasiza-Curry applauded the bill's extension of the Federal matching fund system to races for the US House of Representatives, but noted that this, too, is flawed. "At the same time that the bill tries to make more of our political system free from the influence of money, it puts financial barriers in the way." HR 1 would open Federal matching funds to House candidates who raise at least $50,000 from at least 1000 different donors. "Candidates running outside the 'big 2' are the ones who need this assistance the most, but many of them have a hard time raising even a fraction of that limit. This is not the way to bring more voices into our political conversation."

A few very simple fixes to the bill would make the playing field much more level for third party and independent candidates at both the House and Presidential level, said Moyowasiza-Curry campaign adviser Eric Siegel, a political scientist and pollster based in Oak Park, Michigan. "Keeping the Presidential threshold at $5,000 each in at least 20 states would ensure that campaigns get the boost they need to organize and get their message out, without putting an undue burden on them. And a $5,000 floor for House candidates would maintain the requirement that they show a breadth of support without putting yet another artificial barrier in the way of candidates from outside the traditionally dominant parties. Political science research tells us that more candidate choice leads to higher turnout, and this bill is mostly designed to encourage people to join the process. Why undermine that mission by restricting voters' options?"

Sedinam Moyowasiza-Curry is a declared candidate for the nomination for President of the Green Party of the United States. She ran for the GPUS Presidential nomination in 2016, and for the Vice-Presidential nomination in 2008. She is a longtime Green, and was a co-founder of the Green Party's Black Caucus. To find out more about her 2020 Presidential campaign, visit Sedinam2020.

Public Comment 200: March 2019 -US HOR - 3 Poison Pill Riders

March 2019

Majority Members

Committee on Appropriations

U.S. House of Representatives

H-307 The Capitol

Washington, DC 20515

Dear Chair Lowey and Majority Members of the Committee:

We the undersigned 28 groups write to urge you to ensure three troubling anti- democracy riders from the 2019 spending package do not make it into the 2020 spending bill.

These three poison pill policy riders that protect a democratic system rigged in favor of wealthy special interests are all expressly removed from any future Appropriations bills by H.R. 1, the For the People Act. Following the resounding passage of H.R. 1 by all Democrats in the House there is now a clear mandate for the removal of these riders from the FY2020 Appropriations bill.

Today, our democracy is out of balance, and that makes it harder to solve the big problems facing our country and our communities. Our current system allows powerful corporate and wealthy interests to regularly defy the foundational principles of fairness, equity, ethics, accountability, and respect for the rule of law, with the unfortunate result being a government that is more responsive and accountable to wealthy political donors than to the public. In order to restore balance to our democracy we need to use all of the tools at our disposal. That is why we are writing to draw your attention to three poison pill policy riders that have been snuck into the appropriations process that stymie this progress.

The first rider prevents the Treasury department and the IRS from enacting a sensible definition of political activity that would reduce abuse by those willing to manipulate the system to spend secret money in elections. The second would tie the hands of the Securities and Exchange Commission from finalizing rules that would reveal how big donors and corporations are spending in our elections. The third prohibits federal contractors from being required to disclose their political spending.

The riders, discussed in more detail below, help entrench a political system rigged in favor of wealthy special interests by blocking common-sense transparency rules and maintaining avenues for special interests to secretly influence elections.

Sec. 124 – Preventing the IRS and Treasury from making better rules for 501(c)(4) political activity

This rider prevents the Treasury department from adequately defining what

nonprofits can and can’t do in elections. Without clear guidance, groups wanting

to spend in elections without disclosing their donors can abuse the system free of

consequences.

Sec. 629 – Preventing the SEC from making a rule requiring corporations to disclose political spending

This rider stops the SEC from finalizing a rule requiring public companies to

disclose their political spending. In his decision in Citizens United, the Supreme

Court decision that opened the flood gates for unlimited corporate spending in our

Re: Comments for the Securities and Exchange Commission (SEC) November 15, 2018 Roundtable on the Proxy Process - File Number 4-725

Dear Officers,

The signatories below welcome the opportunity to comment in response to the Securities and Exchange Commission’s (SEC) request for comment on “earnings releases and quarterly reports.” In summary, we urge the SEC to heed the many investor calls for greater disclosure, including political spending, and general environmental, social and governance (ESG) matters.

The SEC’s current exercise follows a comment from President Trump who questioned the value of quarterly reporting. Trump referenced Pepsi CEO Indra Nooyi, who lamented the focus on short-term results.[1]

Generally, we are concerned with a recurring effort at the SEC to reduce disclosure. The only voices supporting such a reduction are corporations. Investors, by contrast, continue to seek greater disclosure. For example, shareholders filed resolutions at 80 companies in 2018 calling for greater disclosure of political spending. More than 1.2 million citizens have signed a petition calling on the SEC to require political spending disclosure. More than 26,500 individuals submitted comments in response to its 2016 Concept Release on Business and Financial Disclosure Required by Regulation S-K and the overwhelming majority supported more and better disclosure in general.[2] Finally, investors representing more than $5 trillion in assets under management filed a new petition in October 2018 for greater disclosure regarding the environment, social and governance issues. (File Number 4-730), generating more than 3,300 comments to date. [3] Again, the investing public seeks greater disclosure, not less.

We recognize the problem of short-termism, of “quarterly capitalism,” of the failure by managers to adopt a long-term perspective needed to grow the economy sustainably. We believe this problem stems not from the frequency of reporting, but from the structure of compensation. Consider what happened to the added income generated by the Trump corporate tax cut measure. Instead of resulting in greater investment or better wages for employees, the most conspicuous expenditures came through buybacks. In turn, these buybacks benefitted managers whose compensation turned on the value of stock options. Compensation pegged to short term stock prices is determined by boards of directors. Should a company wish to adopt a long-term perspective, these boards should structure compensation accordingly.

We the undersigned 28 groups write to urge you to ensure three troubling anti- democracy riders from the 2019 spending package do not make it into the 2020 spending bill. These three poison pill policy riders that protect a democratic system rigged in favor of wealthy special interests are all expressly removed from any future Appropriations bills by H.R. 1, the For the People Act. Following the resounding passage of H.R. 1 by all Democrats in the House there is now a clear mandate for the removal of these riders from the FY2020 Appropriations bill.

Today, our democracy is out of balance, and that makes it harder to solve the big problems facing our country and our communities. Our current system allows powerful corporate and wealthy interests to regularly defy the foundational principles of fairness, equity, ethics, accountability, and respect for the rule of law, with the unfortunate result being a government that is more responsive and accountable to wealthy political donors than to the public. In order to restore balance to our democracy we need to use all of the tools at our disposal. That is why we are writing to draw your attention to three poison pill policy riders that have been snuck into the appropriations process that stymie this progress.

The first rider prevents the Treasury department and the IRS from enacting a sensible definition of political activity that would reduce abuse by those willing to manipulate the system to spend secret money in elections.

The second would tie the hands of the Securities and Exchange Commission from finalizing rules that would reveal how big donors and corporations are spending in our elections.

The third prohibits federal contractors from being required to disclose their political spending.

The riders, discussed in more detail below, help entrench a political system rigged in favor of wealthy special interests by blocking common-sense transparency rules and maintaining avenues for special interests to secretly influence elections.

Sec. 124 – Preventing the IRS and Treasury from making better rules for 501(c)(4) political activity. This rider prevents the Treasury department from adequately defining what nonprofits can and can’t do in elections. Without clear guidance, groups wanting to spend in elections without disclosing their donors can abuse the system free of consequences.

Sec. 629 – Preventing the SEC from making a rule requiring corporations to disclose political spending.This rider stops the SEC from finalizing a rule requiring public companies to disclose their political spending. In his decision in Citizens United, the Supreme Court decision that opened the flood gates for unlimited corporate spending in our elections, Justice Anthony Kennedy assumed that prompt internet disclosures would be the norm. However, this rider stops the type of critical disclosure regime Justice Kennedy envisioned from being implemented and deprives investors and the public of critical information on corporate political activity.

Sec. 735 – Preventing disclosure of political spending by government contractors. The American people have a right to know whether the companies doing their business are being awarded contracts simply because they give big campaign donations.

We appreciate your attention to this important matter, and look forward to your proposal of a funding package free from these damaging measures.

Sincerely,

20/20 Vision

American Atheists

American Family Voices

Boston Common Asset Management

California Clean Money Action Fund

Center for Biological Diversity

Center for Media and Democracy

Citizens for Responsibility and Ethics in Washington

Clean Elections Texas

Coalition to Preserve, Protect & Defend

Common Cause

Democracy 21

End Citizens United Action Fund

Franciscan Action Network

Harrington Investments

Interfaith Center on Corporate Responsibility

League of Women Voters of the United States

MAYDAY America

NETWORK Lobby for Catholic Social Justice

New Mexicans for Money Out of Politics

New Progressive Alliance

Open the Government

Patriotic Millionaires

People For the American Way

Progressive Leadership Initiative

Public Citizen

Ursuline Sisters of Tildonk, US Province

Voices for Progress

Public Comment 203: March 2019 - Congress Oppose Bad Policy Riders

March 29, 2019

Dear Member of Congress,

The Clean Budget Coalition, an alliance of labor, scientific, consumer, research, good government, faith, civil rights, community, health, environmental, and public interest groups, writes you to urge FY20 appropriations bills that are free from poison pill policy riders that harm the public.

No appropriations titles, package of bills, or continuing resolutions (should that be deemed the appropriate path to continue funding the government) should move forward if they contain poison pill policy riders that go against the public interest.

Unfortunately, such poison pill riders have existed as favors to corporate and special interests in previous appropriations cycles, and therefore a set of “legacy poison pills” must be removed from the FY20 appropriations bills. We ask that you take that stance as Congress processes the FY20 appropriations bills—keeping out new poison pills that harm the public and removing those that have become embedded.

Poison pill riders are unpopular and dangerous, and the public opposes the abuse of the budget process to roll back public protections. The budget should be funding the things that Americans care about, not undoing essential safeguards. The American people support policies to:

Ensure safe and healthy food and products;

Restrain Wall Street abuses;

Secure our air, land, water and wildlife;

Safeguard fair and safe workplaces;

Guard against consumer rip-offs and corporate wrongdoing;

Defend our campaign finance and election systems;

Promote economic fairness in banking, housing and business;

Provide access to justice and fair housing;

Protect human and civil rights, including the rights of immigrants; and

Guarantee continued access to vital health care services including comprehensive reproductive health care, among other things.

The public does not support slipping damaging poison pills into must-pass appropriations bills that would undo any of these protections as a means to win approval.

We urge Members of Congress to fully fund important programs and to reject any flawed bills that fail to remove poison pill policy riders that would undo essential public safeguards.

We the undersigned national, state, and local organizations support significant cuts in funding to Immigration and Customs Enforcement (ICE) and Customs and Border Protection (CBP), the agencies behind President Trump’s harmful detention, deportation and border militarization regime.

We are disappointed by the funding increases in the Fiscal Year 2019 Appropriations Bill and call upon Congress to commit to reducing funding for this administration’s white nationalist border militarization and immigration enforcement policies. Taxpayer dollars should be spent on critical programs that make our communities strong and vibrant such as education, healthcare, green infrastructure, and housing rather than fueling abusive agencies that terrorize communities and separate families.

The Trump Administration showed the depths of its cruelty toward immigrant communities in fiscal year 2018. Just at our southern border, Border Patrol agents have forcibly separated thousands of families, tear-gassed asylum seekers including toddlers, and regularly flouted international law by denying the right to seek asylum at the border. This abuse is happening despite the fact that the total number of border apprehensions are at the lowest point in decades and each Border Patrol agent apprehends, on average, fewer than 2 people a month. Deplorable conditions and inadequate medical care in border facilities also contributed to the tragic deaths of two young children, Jakelin Caal Maquin and Felipe Alonzo-Gomez. The border wall has a devastating toll on border communities, wildlife and the environment. President Trump’s declaration of a national emergency shows the administration’s dedication to fear mongering around a manufactured crisis that is built on racist lies and disregard for U.S. and international law.

ICE has continued to grow its vast network of over 200 detention centers, perfecting the agency’s multi-year tactic of overspending its appropriated funds and then repeatedly demanding that Congress bail it out with increased funding for the next year. This gradual ramp up resulted in a historic high in mid-February, of over 49,000 individuals jailed by ICE each day. As ICE expands, more people are dying in ICE custody because of medical neglect, abuse, and a total lack of concern for the value of immigrant lives. ICE also continues to target parents of unaccompanied children, ramp up workplace raids, collude with USCIS to detain people attending biometrics appointments, and arrest people at courthouses all in an attempt to terrorize communities and force them into the shadows.

We are deeply disappointed with the passing of the 2019 Consolidated Appropriations Act because it increases funding to both ICE and CBP, including a 12% increase for immigration detention and $1.375 billion for more border wall, and fails to rein in the agencies’ ability to overspend and siphon money from other accounts. This increase in funding is wholly undeserved due to both agencies’ track records of harmful policies, abuse, and mismanagement. As such, this increase in funding is tacit approval of this administration’s attacks on immigrant communities across the country and those newly arriving at our borders and ports of entry.

As we look forward to fiscal year 2020, we urge Members of Congress to view the budget as a moral document that reflects our priorities and values as a nation. Congress must invest in programs and agencies that uphold our shared values of dignity and justice and divest from programs and agencies that flout those values at every opportunity. It is unacceptable to claim support for immigrant communities while continuing to grow the already inflated budgets for ICE and CBP.

We, the undersigned organizations, call on you to demonstrate bold leadership and commit to reducing funds to ICE and CBP for fiscal year 2020.

It is with increasing frequency and growing magnitude, that the Federal Energy Regulatory Commission (“FERC” or “Commission”) is abusing its authority and the law in alarming ways. After three decades of FERC’s unaccountable and irresponsible approach to energy development, the trust of the American people has been strained beyond the breaking point. And, to be honest, our trust that Congress wants to fix the problem is withering. We are hopeful that you will prove us wrong and become a champion for the kind of meaningful reform that is truly needed.

We are urging you to lead a call for Congressional hearings into the abuses of power and law being inflicted by FERC, infringing on property rights, states’ right, peoples’ rights, and environmental protection. We have assembled a dossier to document FERC’s abuses and brought representatives of beleaguered communities from across the nation to share their experiences in a Peoples Hearing held in Washington DC. Our findings demonstrate that Congressional hearings and investigation are needed.

We are urging you to be a lead voice opposing legislative rollbacks when it comes to review and/or approval of natural gas infrastructure. And we are asking you to champion meaningful reforms that will prevent ongoing and future abuses of power and law by FERC. As it currently stands, the language of the Natural Gas Act (NGA) is being misused by FERC to deny people their legal and constitutional rights, to strip and undermine the legal authority of states, to undermine the authority of other federal agencies, to ignore the mandates of the Clean Water Act and the National Environmental Policy Act, to trample private property rights, to take from communities the protection

of public parks, forests and conserved lands that they have invested heavily in protecting, to take jobs and destroy small businesses, to inflict on our communities health, safety and environmental harms, all for the benefit of a single industry seeking to advance its own corporate profits and business edge over its competitors.

With this letter, we are identifying for you the meaningful reforms that are needed. Recent pronouncements of soft ball legislative proposals will not remedy the abuses communities are suffering. Legislative proposals that are only focused on the public participation process of FERC and not the taking of the judicial, legal, state, property, or environmental rights we have been highlighting are simply not good enough. Soft ball legislative reforms that don’t go to the root of the problems we have been alerting you to will not receive our praise or support. A legislative proposal that is not a true legislative fix is an anathema to us.

These are among the reforms we need:

First and foremost, we need to remove the authority for review and approval of pipelines and other natural gas infrastructure from FERC. With this remedy many of the fixes listed below become no longer necessary.

FERC has demonstrated its bias toward the natural gas infrastructure industry. The abuses and problems are so ingrained reform will be difficult if possible. The most effective approach would be to remove the power of pipeline and LNG approval from FERC and place it in the hands of another agency, one that has clean energy, community and environmental protection goals as its priority mandate, and will do the cumulative and holistic review and decision-making, including prioritizing the clean energy options that are needed to protect communities, protect the environment, and minimize climate changing emissions.

If FERC retains authority over natural gas infrastructure including pipelines and LNG exports, then all of the below fixes are necessary because of the highly biased and abusive way FERC implements current laws including the Natural Gas Act, National Environmental Policy Act, Clean Water Act and others.

Remove the Power of Eminent Domain from FERC authority.

The ability of FERC to give the power of eminent domain to private pipeline companies must be removed. There is no shortage of power in this nation now or in the foreseeable future. In addition, we have viable and growing clean energy pathways to follow, pipeline projects are routinely advanced to support corporate interests and goals rather than public benefit or need, and an increasing number of pipeline infrastructure projects are to serve the export of gas to overseas nations. Given all of these facts, the Commission has no business allowing a private company to use eminent domain for a self-serving project at the expense of American property rights. If a project is not good enough to curry the favor of landowners then it should not be powerful enough to take their property rights.

Remove language that results in preemption of state or local laws or authority for FERC regulated infrastructure projects.

A fundamental underpinning of our nation is respect for the rights of states to govern within their boundaries and to ensure the protection of the health, safety and welfare of their people. States’ rights are carefully honored throughout our nation’s laws and history. Stripping states and municipalities of their legal authority, particularly given the tremendous health, safety and economic harms pipelines inflict on communities is not justified. In addition, there is no reason that natural gas pipeline projects should not be subject to the same laws that all other industries are subject to, and that other arms of the energy industry must comply with. To exempt interstate natural gas infrastructure from the state and local laws that apply to every other industry gives them an inappropriate competitive advantage. This respect for the rights of states to take leadership in the protection of their citizens is carefully recognized and provided for in the area of environmental protection, particularly the implementation of the Clean Water Act.

Clarify the law to make clear that there is no time limit on the state review and approval process regarding FERC regulated infrastructure, including in the context of Clean Water Act 401 Certifications.

Another important change necessary to ensure full and fair respect of states’ rights and authority when it comes to protecting the residents and environments within their state boundaries is ensuring states are given all the time they need to ensure that state water quality standards will be protected if a pipeline is approved for construction within their state boundaries. The Natural Gas Act needs to be clear that states are entitled to all of the time they deem necessary to engage in full review and decision-making on FERC regulated pipeline and infrastructure projects, particularly in the context of implementing Clean Water Act authorities (which for most states is the 401 Water Quality Certification and for states like New Jersey also includes 404 wetlands determinations). The law needs to be clear that state authority is only waived when the state renders an affirmative decision that they are waiving their authority.

Prohibit FERC from approving a pipeline infrastructure project and/or allowing it to proceed with any element of construction until all state and federal reviews/permit processes have been finalized and approvals/permits granted.

Currently, FERC approves pipelines and allows them to proceed through phases of construction and eminent domain regardless of whether or not they have received all necessary reviews and approvals from impacted states who have a legal decision-making role and other federal agencies. Consequently, pipelines have proceeded with the power of eminent domain and significant construction that inflicts irreparable harm on property, economic and environmental interests. The law needs to make clear that FERC cannot approve a project and allow it to proceed with any element of eminent domain or construction until all state and federal reviews/permit processes have been finalized and approvals/permits granted.

If you are unwilling to put in place this comment sense reform then other approaches for addressing the concern could include:

-Clarify the law to make clear that State Section 401 Clean Water Act approvals have primacy in the FERC review and approval process. Section 401 of the Clean Water Act specifically reads: “no [federal] license or permit shall be granted until the certification required by this section has been granted or waived.” 33 U.S.C. § 1341(a)(1). Requiring Section 401 certification from the states prior to federal action ensures that states’ rights are honored, that state standards are met, and that public and private resources are not unnecessarily lost. It also ensures that the federal government is held accountable to the same standards as private entities, an important point of equity. FERC routinely issues Certificates of Public Convenience and Necessity prior to state decision-making on 401 Certifications for FERC pipeline and infrastructure projects. The result is to undermine state authority, and in some instances, has resulted in the taking of property rights, and damage to business, jobs and the environment for construction of a pipeline that a state ultimate rejected. 401 primacy prevents such an irreversibly harmful outcome. If the mandate that 401 Certification must be received prior to FERC providing NGA Certification is not enacted/clarified within the language of the NGA, then it must be clear that FERC cannot approve any element of eminent domain or construction until all state reviews/permit processes have been finalized and approvals/permits granted, including but not limited to 401 Certification.

-Ensure Full Applicability of all Federal Laws. Currently, FERC approves pipelines and allows them to proceed through phases of construction and eminent domain regardless of whether or not they have received all necessary reviews and approvals from other agencies, such as wetland permits from the US Army Corps or completed endangered species review from the U.S. Fish & Wildlife Service. The law needs to make clear that FERC cannot approve a project and allow it to proceed with any element of eminent domain or construction until all state and federal reviews/permit processes have been finalized and approvals/permits granted.

The law should be reformed to require a genuine demonstration of need for a natural gas pipeline infrastructure project.

FERC routinely accepts false or inappropriate claims/demonstrations of need for pipeline infrastructure proposals. As a result, the law needs to be reformed to ensure that a full, fair and legitimate need, one that cannot be fulfilled by clean energy technologies, is demonstrated before a pipeline can even be considered for FERC Certification.

Currently,

-Pipeline companies routinely assert “need” for a project because it will lower costs, improve profits or enhance the ability to compete with others in the gas and/or pipeline industry. These assertions demonstrate corporate goals and desires. None of these scenarios demonstrate public needs that warrant the economic, environmental or property rights harms inflicted by a project and so should be explicitly prohibited.

-Pipeline companies routinely assert need by presenting contracts for pipeline capacity that are from related corporate entities, as such they use their own connected operations to put forth an unverified claim of genuine need. Pipeline companies should be prohibited from engaging in self-dealing in need demonstration – no contractual indealing should be allowed for manufacturing need, i.e. company cannot claim it needs a new pipeline for a gas source that is itself or some subsidiary self or related company that is, in fact, just another form of itself.

-Pipeline companies routinely assert need so the company can tap into an alternative source of gas, regardless that there is no threat to the source for their business use, it is simply a preferred business option. Preferred business operations of this kind should not be allowed for asserting need.

-Pipeline company claims that end of pipeline communities “need” their gas are often debunked by experts in the field who are quickly ignored by FERC in their reviews. Expert reports challenging company claims of need should be given primacy in the review process, rather than being disregarded if in conflict with pipeline claims.

-“Need” considerations uniformly focus on the end goal of securing gas, rather than focusing on the end goal of securing energy. This means that clean energy or other viable alternatives are ignored in the FERC review and approval process. Consideration of need must focus on “energy” needs of the end users and require full and fair consideration of whether clean energy alternatives could fulfill the need for energy identified. Proof of need should include a mandated demonstration that renewable strategy cannot be used to fulfill energy goal being asserted.

- Demonstration of need must be based on more than assertion that a pipeline or export facility has customers, it needs to demonstrate a genuine end-use need that cannot be fulfilled by renewable options;

Revisions of law are needed to address all of these scenarios as none of them demonstrate public needs that warrant the economic, environmental or property rights harms inflicted by a project and so should be explicitly prohibited.

The law needs to be reformed to ensurelegitimate, and independently verified

demonstrations of need are provided for FERC review and consideration. Pipeline

companies must be required to demonstrate a genuine end-use need that cannot be fulfilled by renewable options.

The use of Tolling Orders by FERC to undermine individual, community and states’ rights should be prohibited.

Under federal law, a private party is not allowed to legally challenge FERC approval of a

pipeline project until they have first submitted a rehearing request to FERC, and FERC has affirmatively granted or denied that request. Rather than do one or the other, FERC’s practice is to issue a “tolling order” in response to such requests, which temporarily grants the request but only “for further consideration”. As a result, the public’s ability to challenge the FERC decision is put into legal limbo until such time as FERC renders and issues its final decision regarding the rehearing request. Itis common for FERC to place people in this legal limbo for upto a year or more, while allowing the pipeline company to advance its project, take property, and begin construction.

Much to the shock of legislators, states and communities, tolling orders are routinely used by FERC to place people in legal limbo, unable to challenge a FERC approval of a natural gas infrastructure project even when the Commission has allowed the company to use the power of eminent domain to take property rights and is approving construction and operation of project sections. Tolling orders are demonstrably unfair and simply wrong, and deprive people, communities and states of their legal right to challenge FERC regulated infrastructure projects before they take property rights by eminent domain or inflict irreparable harm on communities and the environment.

As a result:

-Tolling orders should be prohibited. Quite simply the NGA should be reformed to mandate that FERC must respond to rehearing requests within 30 days and if they fail to do so the rehearing request is deemed denied.

If tolling orders are not prohibited then the other most legally equitable mechanism for addressing the problem is to:

-Prohibit projects from advancing in any way, shape or form, including eminent domain and/or construction, if there is an outstanding rehearing request/tolling order;

“Climate change poses an existential threat to our security, economy, environment, and, ultimately, the health of individual citizens. Unlike many of the challenges that our society faces, we know with certainty what causes climate change: It is the result of GHG emissions, including carbon dioxide and methane, which can be released in large quantities through the production and consumption of natural gas. Congress determined under the NGA that no entity may transport natural gas interstate, or construct or expand interstate natural gas facilities, without the Commission first determining the activity is in the public interest. This requires the Commission to find, on balance, that a project’s benefits outweigh the harms, including the environmental impacts from climate change that result from authorizing additional transportation. Accordingly, it is critical that, as an agency of the federal government, the Commission comply with its statutory responsibility to document and consider how its authorization of a natural gas pipeline facility will lead to the emission of GHGs, contributing to the existential threat of climate change.”1

Despite this well stated position of Commissioner Richard Glick, and despite the fact that federal courts have ordered FERC to consider the climate changing impacts of pipelines and associated infrastructure, FERC has taken the position that it does not need to undertake meaningful climate change reviews or take climate change impacts into consideration in their decision-making.

As a result, it is vitally important that the law be reformed to make clear that FERC’s “public interest” duty pursuant to the Natural Gas Act does in fact mandate consideration of the climate change impacts of pipeline infrastructure. In order to fully and properly implement this reform, legislative reforms must mandate, and include, all of the following, that:

-FERC conduct a full accounting of the climate changing impacts of any proposed pipeline infrastructure, and

-that this analysis must include a full and robust Social Cost of Carbon analysis, and

-that this analysis must include both the downstream end uses of the gas to be carried through the pipeline as well as the climate change contributions of the upstream extraction operations necessary to secure the gas that would flow through the proposed pipeline and/or infrastructure under review (including associated drilling and fracking operations, tree removal, associated trucking and industrial operations), and

-that if it is demonstrated that there is a significant climate change impact that will result, FERC “must”/”shall” deny FERC Certification for the project.

Instill Mandatory penalties and stop work orders for violations during construction, operation, and maintenance that are commensurate with the level of harm inflicted. Violations by pipeline companies during construction, operation and maintenance are routine, with hundreds documented for a single project. Also documented is FERC’s failure to ever (never) issue a civil penalty or stop work order to address the violations. As a result, it is more cost beneficial for a pipeline company to ignore environmental protection laws than to comply with them. In addition, violations are reviewed by FERC in terms of company response, rather than magnitude of the severity of the incident. The law mandating penalties needs the level of penalty assessed to be based upon the severity of the environmental and community harm inflicted.

There should be a ban put in place on Liquefied Natural Gas Exports.

If the goal of drilling and fracking is truly energy independence, that end goal is not served through exports. In addition, the level of community harm and sacrifice is too great for an energy supply that is then shipped overseas to support foreign nations, industries and users.

Mandate full and fair application of NEPA and prevent any rollback of this important and iconic information and review legislation. Among the clarifying and confirming provisions required:

-Clarity on prohibition against segmentation and provide an expansive definition of that term;

-Express obligation to ensure cumulative impact reviews and give that term an expansive definition;

-Ensure review includes consideration of the fracking/drilling/shale gas extraction that a project induces and/or supports and the end uses of the gas whether it be a new power plant, export, industrial, residential;

-Ensure consideration of alternatives not limited to alternate routes but includes alternative ways to create the energy that is asserted as needed;

-Mandate robust health and safety impact analyses and prohibit projects that will adversely impact health and/or safety of a community/region.

-Heightened scrutiny of affiliate relationships, wherein regulated utilities are the pipeline customers while their affiliates are investing as pipeline developers. Here's recent Congressional testimony on this particular issue: tinyurl.com/Peress-6-14-16

Provisions need to be placed in the law that ensure an appropriate level of accountability and oversight of the agency to both Congress and the people of the United States.

Provisions should include:

-Prohibit FERC’s use of third party consultants with actual or potential bias.

-Mandate removal of Commissioners that are demonstrated to engage in any degree of conflict in their decision-making.

-Prohibit Commissioners or other agency staff from working for the pipeline, oil or gas industry, or any of their legal, messaging, lobbying or other related representatives, for a period of 5 years prior to, and a period of 5 years post, their employment with the agency. -Require a public advocate be appointed for each pipeline that is representative of environmental resources, property owners, public land interests that will be impacted by the project.

-Put in place stronger requirements for information disclosure and timelines by which info has to be released.

-Mandate Commissioners provide public hearing opportunities before them, as a body, before final decision-making;

-Mandate FERC use latest science in analysis and decision-making;

-Prohibit waivers, variations and/or changes to a project after its application been submitted for review by FERC; if changes are proposed mandate the new proposal be subject to the full agency and public review and approval process.

-Add an environmental justice standard, including community involvement, for pipeline projects that are within a 10 mile proximity of an environmental justice community.

-Prohibit self interest in FERC staff and Commissioners:

-Prohibit investments in companies regulating,

- Prohibit Commissioners or staff from being involved in decisions that benefit directly or indirectly the staff, Commissioner, their families or professional colleagues. ---Mandate public hearings during NEPA process that are within 20 miles of any community that will be impacted by a proposed project;

-Mandate minimum 120 days to comment on any FERC NEPA documents or proposed project approvals.

Require leadership from FERC for renewables:

-change FERC’s mission to include priority obligation to advance renewables;

-seek a way to mandate/incorporate approval of the renewable energy option if it can be demonstrated to fulfill the claimed energy need being advanced by the pipeline company. -mandate FERC carry out a robust climate change analysis and if approval of a project demonstrates it will contribute climate change emissions and cannot demonstrate (when considering cradle to grave impacts of the source and/or end use of the gas) it will improve climate change conditions then FERC is mandated to reject the project.

For thirty years FERC has served as a rubber stamp agency for pipeline and LNG infrastructure. It has misused its authority and the law at every turn in order to advance these projects. Meaningful and substantive reforms are needed. Ideally Congress will hold Congressional hearings to expose the abuses and help identify and shape the reforms needed. But given that legislators are increasingly putting forth window dressing fixes rather than the strong substantive reforms needed, we provide this robust list of fixes that need to be pursued firmly, quickly and without compromise.

We, the undersigned organizations, urge the Appropriations Committees to maintain the District of Columbia FY2020Appropriations Bill as introduced. The bill, introduced last night, respects self-governance of the District of Columbia and maintains local control for the residents of Washington, DC.

Should the bill be amended, we are concerned that the FY’20 Spending Bill will, yet again, attempt to undermine local decisions made by the people of the District of Columbia and their locally elected leadership. These local laws were enacted to address concerns that are important to the more than 700,000 residents who call Washington, DC home. When Congress attempts to impose legislative “riders,” they seek to overturn the work of our locally elected officials and ignore the voices of our neighbors. Such riders would have a grave impact on criminal justice reform, local budget control, gun violence prevention, end-of-life medical decisions, and reproductive freedom. These riders usurp the autonomy granted to the District and our elected mayor and council and overstep the original intent of both the creation of the District and the Home Rule Act.

We understand that some in Congress are still seeking to use the appropriations process to impose policy riders upon the people of the District. The undersigned organizations, collectively representing millions of Americans, advocate on diverse issues and are united in our opposition to the inclusion of any language in the appropriations bill that overrides, limits, or otherwise usurps local government decision-making by the District of Columbia.

We also urge Congress to refrain from taking action that could threaten the District’s Local Budget Autonomy Act. The Act allows the District to spend local tax dollars based on the local budget at the beginning of each fiscal year. The DC Superior Court has held that the Autonomy Act is valid and the DC Council and the Mayor of the District are proceeding with the FY’20 local budget in accordance with the law.

Previous appropriations bills have included a provision barring the District from using local funds to provide insurance coverage of abortion care for individuals enrolled in the Medicaid program. While the Hyde Amendment currently restricts the federal funding for abortion care, states are able to use their own funds to cover abortion care for low income individuals. D.C. is the only locality that is restricted by Congress from using its own local funds to ensure equal access to abortion coverage.

Additionally, Congress has interfered with local laws that prevent discrimination based on an individual’s reproductive health decisions. The Reproductive Health Non-Discrimination Act ensures people are not penalized at work for their personal reproductive health care decisions.No employer has the right to know about personal medical decisions, much less act on them. It should not be the business of Congress to overturn local laws that protect local workers.

Further, previous congressional efforts attempted to overturn, and continue to block, voter initiatives to change marijuana laws that were shown to unfairly target minorities. Congress has gone so far asto bar the District from counting votes on a citizen-led initiative. Most recently, an initiative won the support of over 70 percent of District voters. In the end, the process has created a confusing conflict of laws unique to the District allowing for medicinal and personal use of marijuana but not allowing Washington DCto tax and regulate its sale. In short, congressional meddling has kept the sale of marijuana unregulated and uncontrolled.

Each year, DC faces the threat of legislation that bars local spending on critically needed HIV/AIDS prevention programs. Congressional interference into these local matters is unfair and intolerable. It is a gross misinterpretation of both the United States Constitution and the Home Rule Act. Right now, Americans are debating these and other issues in communities throughout this country. But, what is not up for debate is who gets to decide these questions. DC’s locally elected leadership should decide what is best for the people of the District of Columbia. Or, as former Oversight Committee Chairman Rep. Trey Gowdy said, he “…was not the Mayor of the District of Columbia.” The Mayor and the Council of the District of Columbia were elected byDC residents to represent our interests. Congress does not impose its views on any other local jurisdiction, and Americans inDC have no vote in the Congress to cast against this ongoing, relentless attack on local democracy. Until such time that the residents of the District achieve full equality through Statehood, we expect Congress to allow District residents to manage their own affairs without interference or meddling.

We urge the Committees to preserve the legislation as introduced and oppose any rollbacks of local autonomy and any other efforts that seek to impose Congress’ views upon DC residents.

Sincerely,

DC Vote

American Civil Liberties Union

American Civil Liberties Union - DC

Alliance for Justice

American Family Voices

Americans for Democratic Action

Anacostia Coordinating Committee

BYP100 DC

Catholics for Choice

Center for Environmental Health

Center for Popular Democracy

Clean Water Action

Collective Action for Safe Spaces

Common Cause

Compassion and Choices

DC for Democracy

DCMJ

DC Statehood Coalition

Democracy for America

Democracy Initiative

DEMOS

Endangered Species Coalition

FairVote Action

Food and Water Watch

Friends of the Earth

Gay and Lesbian Activists Alliance

Gertrude Stein Democratic Club

HIPS

Human Rights Campaign

League of Women Voters of the United States

League of Women Voters of DC

Let America Vote

NARAL Pro-Choice America

National Center for Lesbian Rights

National Center for Transgender Equality

National Coalition on Black Civic Participation

National Employment Lawyers Association

National Fair Housing Alliance

National Partnership for Women & Families

National LGBTQ Task Force Action Fund

National Women’s Law Center

Neighbors United for DC Statehood

New American Leaders Action Fund

New Progressive Alliance

Our Revolution

People Demanding Action

People For the American Way

Planned Parenthood Federation of America

Planned Parenthood of Metropolitan Washington DC

Pride at Work

Public Justice Center

Public Citizen

Rural Coalition

SEIU 32BJ

Sexuality Information and Education Council of the United States (SIECUS)

Sierra Club

Small Planet Institute

Stand Up for Democracy in DC (Free DC)

Unite HERE Local 25

URGE: Unite for Reproductive & Gender Equity

UUA Multicultural Growth & Witness Staff Team

Voices for Progress

Workplace Fairness

CC:Congresswoman Eleanor Holmes Norton

Public Comment 207: June 2019 - US HOR - Health Infrastructure

June 10, 2019

Chairman Frank Pallone

Energy & Commerce Committee

U.S. House of Representatives

Washington, DC 20515

Dear Chairman Pallone:

On behalf of the undersigned organizations, we write in support of provisions in the Leading Infrastructure For Tomorrow’s America Act (LIFT America Act) to invest in America’s public health infrastructure. Public health is a crucial part of the nation’s essential infrastructure, and investing in it will save lives and money.

All too often, the Centers for Disease Control and Prevention (CDC) and health departments are under-resourced and under-staffed.i A recent report by Trust for America’s Health, The Impact of Chronic Underfunding on America’s Public Health, found that chronic underfunding has presented a consistent obstacle that is preventing the public health system from adequately tackling leading health threats.ii America spends about $3.5 trillion on healthcare, less than three percent of which supports governmental public health.iii In fact, a study out of the University of Kentucky estimated a total shortfall of about $13 per person – or $4.5 billion for the entire nation – to implement comprehensive public health capabilities.iv As recent public health crises, like the measles outbreaks and substance misuse epidemic, have shown, a comprehensive, well-resourced public health system and workforce is needed for effective responses.

The CDC as well as state, local, tribal and territorial health departments, public health laboratories, and community partners need a well-functioning infrastructure to prevent and respond to major health harms. That infrastructure includes facilities and equipment, such as governmental laboratories; up-to-date data and information systems; and a highly skilled and qualified workforce - including those who are the front lines when a deadly infectious disease or dangerous environmental hazard needs to be contained.v,vi The LIFT America Act would authorize funding for cross-cutting core public health and laboratory infrastructure, rather than funding disease-specific capabilities, enabling public health to be nimble in prevention of and response to a range of emerging health conditions. The legislation would invest in workforce capacity and competency, laboratory systems, health information systems, communications, financing and other critical components.

In addition, the success of public health relies upon accurate and timely data, but there are health departments that are still communicating time-sensitive information the way they did a half century ago– by phone, fax and paper. Public health information systems are dependent on outdated technology, systems that are not interoperable, and lack of adequately trained workforce. These outdated systems are delaying public health’s ability to detect outbreaks, communicate with clinicians, and target interventions to prevent disease. The LIFT America Act authorizes critical investments in the public health data infrastructure to transform the speed and accuracy of public health surveillance. Doing so will enable faster detection and containment of outbreaks, with fewer cases – saving lives and reducing delays in response.

As the Zika, Ebola and H1N1 outbreaks, opioid epidemic, natural disasters and rise in chronic diseases have demonstrated, health threats are increasing in frequency and severity, undermining the nation’s economic and health security. U.S. life expectancy has declined for the third year in a row, the longest sustained decline in expected life span since 1918.vii A pandemic could cost the U.S. economy as much as $45 billion.viii And an unhealthy workforce adds billions in direct and indirect costs to the healthcare system and economy. Yet, public health systems and program spending have been shown to have a positive return on investment and improvement in health outcomes – including reducing preventable deaths.ix, x, xi But public health must have the resources to modernize.

Public health is as critical to the nation’s success as roads, bridges, and communications systems. We stand ready to work with Congress to authorize and fund these transformative investments in public health infrastructure.

Sincerely,

AES Consulting

African American Health Alliance

Alameda County (CA) Health Care Services Agency

Alliance of Nurses for Healthy Environments

All Youth Access

American Association of Colleges of Pharmacy

American College of Preventive Medicine

American Foundation for Suicide Prevention

American Medical Informatics Association (AMIA)

American Public Health Association

American Society of Tropical Medicine & Hygiene

American Thoracic Society

Association for Professionals in Infection Control and Epidemiology

Association of Maternal & Child Health Programs

Association of Public Health Laboratories

Association of Schools and Programs of Public Health

Association of State and Territorial Dental Directors

Association of University Centers on Disabilities

Benzie Leelanau (MI) District Health Department

Big Cities Health Coalition

Boulder County Public Health

Cardiometabolic Research Institute

Center for Infectious Disease Research and Policy (CIDRAP)

Center for Science in the Public Interest

Central Michigan Regional Rural Health Network

Colorado Association of Local Public Health Officials

Community Action, Service & Advocacy (CASA)

Council of State and Territorial Epidemiologists

Cuyahoga County Board of Health Delaware Ecumenical Council on Children and Families

Public Comment 208: July 2019 – US Senate Allow SEC to Mandate Disclosure of Political Spending

July 25, 2019

Dear Senator:

The undersigned organizations urge you to vote in favor of Menendez amendment #3532 to strike the language in section 629 of the Senate 2019 Financial Services and General Government Appropriations bill. The provision would limit the Securities and Exchange Commission’s (SEC) ability to finalize, issue, or implement a rule requiring public companies to disclose political spending to shareholders.

Since the U.S. Supreme Court’s decision in Citizens United v. FEC came down in 2010, corporations have been allowed to spend unlimited undisclosed amounts of money to influence American elections and in turn affect policy outcomes. Noting the danger of “dark money” for both American democracy and the shareholders of the companies that are spending in secret, a strong coalition of diverse allies has been working together since the decision to bring corporate spending in politics into the light.

We, the undersigned organizations, believe the SEC should be allowed to and encouraged to move forward with the rulemaking that would require public companies to disclose to their shareholders and the public how they spend money in politics. This information is material to investors- the constituency the SEC is responsible for protecting.

The Supreme Court’s decision to give corporations the right under the First Amendment to spend unlimited funds from their corporate treasuries to support or attack candidates is troubling for several reasons, and investors concerned about the value of their investments and citizens concerned about the future of American democracy are looking to the SEC to take the action that so many investors have demanded and require disclosure of political spending.

Without direction from the SEC, there are no rules or procedures established in the United States to ensure that shareholders – those who actually own the wealth of corporations – are informed of, or have the right to approve, decisions on spending their money on politics. Investors want more disclosure in order to make sound investment decisions. That is why 1.2 million comments- the most in the agency’s history- have come into the SEC on this rulemaking petition from diverse stakeholders including the founder of Vanguard, John Bogle, five state treasurers, a bi- partisan group of former SEC chairs and commissioners, and investment professionals representing $690 billion in assets.

We believe that the rider blocking the SEC from making progress on this rulemaking was inappropriately included in the appropriations process and that the budget should be free of any poison pill policy riders. We urge you to vote in favor of the Menendez amendment #3532 to strike section 629. We are grateful for your leadership and appreciate your consideration of this request to restore transparency and accountability to our democracy.

Sincerely,

American Federation of Labor and Congress of Industrial Organizations (AFL-CIO)

Dear Chairwoman Maloney, Ranking Member Huizenga, and Members of the Subcommittee,

The undersigned organizations respectfully offer the following comments to the record for the hearing titled “Building a Sustainable and Competitive Economy: An Examination of Proposals to Improve Environmental, Social and Governance Disclosures.” We applaud the committee for looking broadly at ESG disclosure and, in particular, at corporate political spending disclosure, which is addressed in the Shareholder Protection Act legislation introduced as a discussion draft for this hearing.

Since the U.S. Supreme Court’s decision in Citizens United v. FEC came down in 2010, corporations have been allowed to spend unlimited undisclosed amounts of money to influence American elections and in turn affect policy outcomes. Noting the danger of “dark money” for both American democracy and the shareholders of the companies that are spending in secret, a strong coalition of diverse allies has been working together since the decision to bring corporate spending in politics into the light.

We, the undersigned organizations, believe the Securities and Exchange Commission (SEC) should be allowed to and encouraged to move forward with the rulemaking that would require public companies to disclose to their shareholders and the public how they spend money in politics. This information is material to investors- the constituency the SEC is responsible for protecting.

The Supreme Court’s decision to give corporations the right under the First Amendment to spend unlimited funds from their corporate treasuries to support or attack candidates is troubling for several reasons, and investors concerned about the value of their investments and citizens concerned about the future of American democracy are looking to the SEC to take the action that so many investors have demanded and require disclosure of political spending.

Without direction from the SEC, there are no rules or procedures established in the United States to ensure that shareholders – those who actually own the wealth of corporations – are informed of, or have the right to approve, decisions on spending their money on politics. Investors want more disclosure in order to make sound investment decisions. That is why 1.2 million comments- the most in the agency’s history- have come into the SEC on this rulemaking petition from diverse stakeholders including the founder of Vanguard, John Bogle, five state treasurers, a bi- partisan group of former SEC chairs and commissioners, and investment professionals representing $690 billion in assets.

A company’s political activity- both its election spending and lobbying- is relevant to its shareholders because it can present significant reputational risk if not disclosed and managed properly. Many customers and the purchasing public are paying close attention to whether a company’s political activity lines up with its corporate values. If there is a disconnect companies can face bad press, boycotts, or targeted social media campaigns.

For example, AT&T came under public scrutiny after it was revealed that the company paid attorney Michael Cohen--who has since been sentenced to three years in prison for campaign finance violations and fraud--$600,000 to consult on policy matters without disclosing that information to shareholders. This was following five years of calls from AT&T’s shareholders to disclose the full extent of its lobbying activity and oversight policies, including payments for direct and indirect lobbying. Clearly shareholders were right to make this demand. It is important for companies to be transparent in order to prove corporate integrity and reputational soundness.

Shareholder proposals calling on companies to be honest about their political activity are one of the most frequently filed proposals every year, with 93 filed at the start of the 2019 proxy season.

The undersigned organizations have been encouraging the Commission to promptly initiate a rulemaking to develop mandatory rules for public companies to disclose their political activity and we applaud members of the House for drawing attention to this critical issue.

Sincerely,

Common Cause

Democracy 21

End Citizens United Action Fund

Interfaith Center on Corporate Responsibility

New Progressive Alliance

OIP Trust/Missionary Oblates

Pax World Funds

Public Citizen

Sierra Club

Sisters of Charity of Saint Elizabeth

The Union of Concerned Scientists

Public Comment 210: August 2019 - Congress - Amendment to Overturn Citizens United

August, 2019

Dear Honorable Members of 116th Congress:

Large donors now dominate elections in the United States, silencing the voices of average Americans and making government unresponsive to their needs. We are writing to urge you to co-sponsor H.J.Res. 2, the bipartisan Democracy for All Amendment, which would restore the authority of Congress and the states to set common-sense rules for the raising and spending of money on elections to advance political equality for all Americans.

The American people continue to demand action from Congress on this issue. Indeed, on Thursday, June 6th, 2019, New Hampshire became the 20th state to call on Congress to pass a Constitutional Amendment to address the harm caused by the Supreme Court’s Citizens United v. FEC decision and related cases. New Hampshire joins nineteen other states and over 800 cities and towns across the country, representing more than 140 million Americans, that have passed similar resolutions since 2010.

The U.S. Supreme Court’s decision in Citizens United is one of several cases that opened the doors to vastly more special interest money in elections. If the wealthy individuals and concentrations of capital can drown out the voices of ordinary Americans in elections, we cease to be a representative democracy.

Amending the Constitution should only be done in the rarest of circumstances. The Supreme Court’s decisions have pushed America to a tipping point in which big-moneyed interests exert control over all levers of government. America needs to be responsive to the people, not to corporations and special interests, or it is no longer a democratic republic. We urge you to become a co-sponsor of H.J.Res. 2, the Democracy for All Amendment, so ordinary Americans can meaningfully participate in our elections and government.

Sincerely,

20/20 Vision

350.org

Action Group Network

African Americans Ministers In Action

Alaska Public Interest Research Group (AkPIRG)

Alliance for Youth Action

American Federation of State, County and Municipal Employees

American Federation of Teachers

American Promise

BiNet USA

Blue Future

Brave New Films

Campaign for Accountability

Campaign for America's Future

Center for Biological Diversity

Center for Media and Democracy

Center for Science and Democracy — Union of Concerned Scientists

CenterLink: The Communinity of LGBT Centers

Clean Elections Texas

Clean Water Action

Climate Hawks Vote

Climate Law & Policy Project

Coalition to Preserve, Protect & Defend

Coalition to Restore Democracy

CODE PINK

Color Of Change

Common Cause

Common Defense

Communications Workers of America

Conference of Superiors of Men (Catholic)

Congregation of Our Lady of Charity of the Good Shepherd, U.S. Provinces

Corporate Accountability

Courage Campaign

CREDO Action

Daily Kos

Democracy 21

Democracy Matters

Democratic Coalition

Demos

Disciples Justice Action Network

End Citizens United Action Fund

Endangered Species Coalition

Equal Citizens

Food & Water Watch

Frac Sand Sentinel-Project Outreach

Franciscan Action Network

Free Speech For People

Friends of the Earth

Get Money Out – Maryland

Global Witness

Government Information Watch

Greenpeace

Herd on the Hill

Hip Hop Caucus

Indivisible

Indivisible Kansas City

Indivisible Madison

Institute for Agriculture and Trade Policy

International Corporate Accountability Roundtable

Iowa Citizens for Community Improvement

League of Conservation Voters

LeftAction

Main Street Alliance

MAYDAY America

Modern Military Association of America

MomsRising

MoveOn

MOVI, Money Out Voters In

NAACP

National Action Network

National Advocacy Center of the Sisters of the Good Shepherd

National Association of Social Workers

National Black Justice Coalition

National Council of Churches

National Education Association

National Equality Action Team (NEAT)

National LGBTQ Task Force Action Fund

National Priorities Project at the Institute for Policy Studies

NETWORK Lobby for Catholic Social Justice

New American Leaders Action Fund

NH Labor News

New Mexicans for Money Out of Politics

New Progressive Alliance

North American Climate, Conservation and Environment(NACCE)

Occupy Bergen County (New Jersey)

Patriotic Millionaires

Pay 2 Play

Peace Action

People Demanding Action

People For the American Way

People's Action

Pride at Work

Progressive Turnout Project

Public Citizen

Reclaim Our Democracy

RootsAction.org

Service Employees International Union (SEIU)

Sexuality Information and Education Council of the United States (SIECUS)

The New Progressive Alliance at http://newprogs.org/ urges you to deny the permit for Puget Sound Energy’s liquefied natural gas (LNG) facility because it is based upon an inadequate supplemental environmental impact statement (SEIS).

The SEIS is inadequate for four reasons.

The first reason the SEIS is inadequate is it fails to address the dangers of natural gas and unnecessarily locks us into decades of fossil fuel use in the middle of a climate crisis. The answer is not natural gas obtained by fracking - "in essence, explode a pipe bomb a few thousand feet beneath the surface, fracturing the surrounding rock." (reference 594) Unregulated by the EPA because of congressional action combined with the support of Presidents Obama and Trump, companies refuse to even reveal the chemicals they are "fracking" with, nobody is monitoring the pollution to water and our aquifiers, and nobody is factoring the release of methane as a GHG. Of the 750 chemicals that can be used in the fracking process, more than 650 of them are toxic or carcinogens, according to a report filed with the U.S. House of Representatives in April 2011.

The second reason the SEIS is inadequate is because comprehensive science just is not there. It is based on inaccurate science that does not properly assess the climate impacts of methane. The analysis in the SEIS inaccurately and inadequately accounts for the greenhouse gas emissions associated with this proposal by making misleading assumptions regarding the source, leakage rate, and warming potential associated with gas servicing the facility. Furthermore, PSCAA has done nothing to ensure that gas supplied to the LNG facility would be put toward the end uses evaluated in the SEIS.

The third reason the SEIS is inadequate is the Puget Sound Clean Air Agency did not engage in meaningful consultation with the Puyallup Tribe as required by law and thus ignoring adverse impacts this project would have on the community. It is obvious the SEIS did not engage in meaningful consultation with the Puyallup Tribe both because of the Puyallup Tribe leaders and the SEIS itself.

The fourth and final reason the SEIS is inadequate is it does not uphold the Puget Sound Clean Air Agency mission to “protect public health, improve neighborhood air quality, and reduce our region’s contribution to climate change.” The New Progressive Alliance urges the Puget Sound Clean Air Agency to be true to your mission and deny the permit for Puget Sound Energy’s liquefied natural gas (LNG) facility.